We had intended to publish an update on the continuing saga of Booz Allen Hamilton’s (BAH) continuing demonstration of its corporate ignorance of fundamental procurement rules even before we saw this snarky story from Scott Amey at POGO. You remember our original article on BAH’s problems with its San Antonio office, don’t you? It’s received more than one thousand hits as this article is being written.

Poor BAH. In our previous article, we provided a reported quote by the “debarring official” of the U.S. Air Force. That individual reportedly said—

The conduct … raises serious concerns regarding [BAH’s] business integrity, business honesty, and compliance with government contracting requirements, and the adequacy of BAH San Antonio’s ethics and compliance program, including the training provided to its employees.

We agreed with those sentiments. But we were careful to distinguish the conduct of a few, clearly ill-informed and poorly trained, BAH employees in the organization’s San Antonio office from the conduct of the thousands of well-informed and well-trained BAH employees housed in offices around the world. The improper actions of a few should not taint the actions of the vast majority. And in a similar vein, the USAF was careful to suspend, and move for debarment, of just the single BAH office in San Antonio, and not the entire BAH organization that reports more than $5 Billion in annual sales. We’ve all learned from the inequitable treatment of Arthur Andersen’s personnel, almost all of whom had nothing to do with the Enron account—and so now we aim for a proportionate response to a limited problem (or so we’d like to believe).

But now we aren’t so sure that the problems at BAH are limited to a single Texas office.

The POGO story linked-to at the beginning of this article focused on the hiring of BAH by the Securities and Exchange Commission (SEC) for “management support services,” asserting that the SEC incurs a premium of more than 50% from the substitution of BAH personnel for its own employees. The cost of outsourcing government jobs has been a POGO concern for a while, as we reported here. But that’s not the part of the story that caught our eye. No.

What caught our eye was the part of the story where POGO reported that a retired Navy employee by the name of Gregory R. Penk, had pleaded guilty to unlawfully disclosing “procurement contractor bid and source selection information” … to Booz Allen Hamilton.

Here’s a link to the official Department of Justice press release. And here’s a link to a local newspaper story on the same topic (which, quite frankly, adds very little if anything to the DOJ release).

According to the DOJ—

On June 30, 2010, the Navy solicited bids for a new Naval Air Warfare Center - Aircraft Division (NAWCAD) contract as part of a competitive procurement process. The services had previously been provided by Booz Allen Hamilton (BAH), one of the companies submitting bids on the new contract. Penk was responsible for assisting the contracting officer with funding, performance and technical issues related to the program.

Penk admitted that on three separate occasions, he disclosed contractor bid and source selection information about the NAWCAD contract to BAH. Specifically, on February 14, March 2 and March 4, 2011, Penk called a BAH employee and provided specific information about the contract, including the fact that BAH might not win the project and that BAH’s bid was $7.5 million higher than a competitor’s bid. Penk also informed the employee that the Navy would be issuing a best and final offer request and that BAH should prepare for that request. Penk disclosed the information to give BAH a competitive advantage in the award of the contract.

The Navy learned about Penk’s illegal disclosures and had to rebid the contract.

The BAH office in San Antonio was focused on proposing for work at an Air Force facility. Presumably, this is a BAH office in Maryland or Washington, D.C., proposing for work at a Naval facility. Yet despite differences in military services, geographic location, and in the type of work being solicited, there are some noticeable commonalities. Do you see them?

Yeah, it’s not hard to see that both of these groups of BAH employees shared a common ignorance of expected standards of legal conduct in the government procurement environment, a common ignorance of expected standards of ethical conduct within BAH, and/or a willful and intentional disregard of those standards of conduct.

Remember at the beginning of this article when we said “The improper actions of a few should not taint the actions of the vast majority?” Remember that sanctimonious equine fecal matter? Yeah; now we’re rethinking that.

Now we’re wondering at the actual proportion of ethical employees at BAH versus the unethical few. Now we’re wondering who’s in the majority, and who’s in the minority within that organization.

And we wonder if the folks within the Naval law enforcement community are wondering the same thing.